Safety Management System requirements for Commercial Vessels.

A breakdown of domestic commercial vessel safety management system requirements in Canada and the United States of America.


Transport Canada has amended the Safety Management Regulations. The following Canadian vessels will be required to adopt a SMS in compliance with the ISM Code:

A vessel subject to Chapter IX of the International Convention for the Safety of Life at Sea (SOLAS).

§ 500 gross tonnage and upwards.

§ Certified to carry more than 50 passengers, and

§ More than 24 meters in length and less than 500 gross tonnage.

The proposed regulations are based on the International Safety Management (ISM) Code however, incorporate existing acts, regulations, and standards that are consistent with the Canada Shipping Act, 2001. Until this work is completed, vessel owners and operators are encouraged to voluntarily develop a SMS in compliance with the ISM Code.

Consult Maritime in partnership with Ocean Time Marine can assist you with compliance for ISM and mini ISM with their Safety Management System (SMS) Software / Template..

United Sates of America:

Fishing Vessels:

Commercial Fishing Industry Vessel Safety Act (CFIVSA) of 1988 the US Coast Guard regulations for safety equipment and operating procedures for fishing. Examinations and Certificates of Compliance Dockside safety examinations are now mandatory for vessels operating beyond three nautical miles. These examinations are completed every two years. A certificate of compliance will be issued to a vessel successfully completing the exam. Developing a Safety Management System makes this process easier.

Passenger Vessels:

A US Passenger Vessels on a domestic voyage are encouraged to participate in the program. Based on the requirements of the International Safety Management (ISM) Code and 33 CFR 96. This is a Voluntary ISM program that applies to a domestic voyage.

Any responsible person and their company who owns and operates a U.S. flag vessel which is not engaged in a foreign voyage, may voluntarily meet the standards of 33 CFR 96 and Chapter IX of SOLAS and have their safety management systems certificated.

Super Yachts:

The Large Yacht Code incorporates guidelines for the implementation of a safety management code for vessels between 200 GT and 500 GT.

USCG Towing Vessels – Sub Chapter M:

The final Subchapter M regulation was published on June 20, 2016, and went into effect on July 20, 2016. The requirements are delayed for two years or until a vessel is issued a Certificate of Inspection (COI).

Domestic towing vessel operators are now tasked with preparing their fleets to comply with most of the requirements outlined in 46 CFR Subchapter M by July 20, 2018. To reduce the burden placed on industry stakeholders, the USCG has mandated a four-year phase-in period for towing vessel owners to obtain COIs for 25 percent of their fleets each year. The first 25 percent of an owner’s towing vessel fleet must be certificated on or before July 22, 2019. An additional 25 percent certificated each year until the final deadline of July 19, 2022. All affected towing vessels must hold valid COIs by July 2022. Owners only operating one towing vessel must obtain a COI for that vessel by July 20, 2020.

An operator may choose to achieve and maintain certificated status through the Coast Guard inspection option or the Towing Safety Management System (TSMS) option. The TSMS option requires towing vessel owners to schedule an annual towing vessel survey that meets the scope of 46 CFR 137.220.

The published regulation refer to 46 CFR SUB Chapter M, Part 138 Towing Safety Management System (TSMS)